Epstein Secrets

ry matter with you and other individuals in your office in November 2008. At that time, Mr. Roy Black met with you, Karen Atkinson, Bob Senior, and Jeffrey Sloman in Miami to review the work release issue. Among other significant documents, we presented you with your EFTA00731119 Ms. A. Marie Villafana, Esq

med Mr. Acosta's agreement to postpone the state plea deadline until after the matter was reviewed. On that same day, First Assistant U.S. Attorney Sloman responded in writing as follows: "Please be assured that it has not, and never has been, this Office's intent to interfere or restrict the `review p

ber 4, 2007 letter, Mr. Acosta stated that he supported the defense's appeal to Washington. See December 4, 2007 letter from U.S. Attorney Acosta to K. Starr with a copy to AAG Alice Fisher at p. 5 ("I do not mind this Office's decision being appealed to Washington, and have previously directed our prose

orized release; Material Severable; Redaction; No Assertion by Victims Box #2 P-008517 Thru P-008535 6/25/2007 Letter from Gerald Lefcourt to Jeffrey Sloman and Andrew Lourie [pursuant to Court's Order, not being withheld as privileged — will be produced to opposing counsel upon lift of stay by I Ith

onship; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box #3 P-013334 Thru File folder entitled "11/13/07 Sloman to Lefkowitz (was this sent?)" containing draft 11/13/07 letter from J. Sloman Attorney-Client Privilege Inadequate Log; No Factual Underpinnings

ssue Suppl. Box #3 P-013338 Thru 013341 File folder entitled "12/6/07 Sloman to Lefkowitz" containing 12/5/07 faxed letter w/ cover sheet from K. Starr and J. Lefkowitz to A. Acosta [Not considered privileged. Will be produced to opposing counsel upon lifting of stay] N/A Suppl. Box #3 P-013

negotiations Work Product Deliberative Process Investigative Privilege 12 8/3/2007 Email from Marie Villafafia to Matt Menchel, Andrew Lourie, Jeff Sloman, and Karen Atkinson regarding draft response to correspondence from Epstein counsel and planned investigative steps if agreement cannot be reache

request to delay his change of plea WP DP 83 11/2/2007-11/5/2007 emails between AMCV and Jeff Sloman regarding drafting 11/5/2007 letter from Sloman to Lefkowitz WP DP 84 11/5/2007-11/7/2007 emails from AMCV to Jeff Sloman inquiring about status of matter and contact by Epstein investigators

Suppl. Box #3 P-013338 Thm 013341 File folder entitled "12/6/07 Sloman to Lefkowitz" containing 12/5/07 faxed letter w/ cover sheet from K. Starr and J. Lefkowitz to A. Acosta [Not considered privileged. Will be produced to opposing counsel upon lifting of stay) Suppl. Box #3 P-013342

e Also contains documents subject to privacy rights of victims who are not parties to this litigation Box #3 P-013227 April 23, 2008 Memo from Jeffrey Sloman to Office of Professional Responsibility re Self Reporting, Corrected Version of the previously submitted April 21, 2008 Letter to OPR Privacy Ac

ter with attorney handwritten notes Attorney-Client Privilege Work Product Suppl. Box #3 P-013334 Thru P-013337 File folder entitled "11/13/07 Sloman to Lefkowitz (was this sent?" containing draft 11/13/07 letter from responding to J. Lefkowitz's letter Attorney-Client Privilege Work Product

Suppl. Box #3 P-013338 Thru 013341 File folder entitled "12/6/07 Sloman to Lefkowitz" containing 12/5/07 faxed letter w/ cover sheet from K. Starr and J. Leflcowitz to A. Acosta (Not considered privileged. Will be produced to opposing counsel upon lifting of stay] Suppl. Box #3 P-013342

orized release; Material Severable; Redaction; No Assertion by Victims Box #2 P-008517 Thru P-008535 6/25/2007 Letter from Gerald Lefcourt to Jeffrey Sloman and Andrew Lourie [pursuant to Court's Order, not being withheld as privileged — will be produced to opposing counsel upon lift of stay by 11th C

onship; Claims Against Public Prosecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box #3 P-013334 Thru File folder entitled "11/13/07 Sloman to Leflcowitz (was this sent?)" containing draft 11/13/07 letter from J. Sloman Attorney-Client Privilege Inadequate Log; No Factual Underpinning

Issue Suppl. Box #3 P413338 Thru 013341 File folder entitled "12/6/07 Sloman to Lefkowitz" containing 12/5/07 faxed letter w/ cover sheet from K. Starr and J. Lefkowitz to A. Acosta [Not considered privileged. Will be produced to opposing counsel upon lifting of stay N/A Suppl. Box #3 P41334

d as a sex offender and objected to any sentence short of incarceration. The Assistant State Attorney in charge of the sex-crimes unit reported Mr. Sloman's conduct during the proceedings as "outrageous." The defendant's attorney described Mr. being "out of control." Shortly after, Mr. began publicl

uraging civil lawsuits against Mr. Epstein under the guise of the terms of the Non Prosecution Agreement. See Tab 35, November 28, 2007 Letter from K. Starr to A. Fisher. 43. Late in the day on November 28, Epstein's attorneys received from AUSA a copy of the USAO's proposed victim-notification letter

er with attorney handwritten notes Attorney-Client Privilege Work Product Suppl. Box #3 P-013334 Thru P-013337 File folder entitled "11/13/07 Sloman to Lefkowitz (was this sent?)" containing draft 11/13/07 letter from J. Sloman responding to J. Lefkowitz's letter Attorney-Client Privilege Wo

Suppl. Box #3 P-013338 Thru 013341 File folder entitled "12/6/07 Sloman to Lefkowitz" containing 12/5/07 faxed letter w/ cover sheet from K. Starr and J. Lefkowitz to A. Acosta [Not considered privileged. Will be produced to opposing counsel upon lifting of stay] Suppl. Box #3 P-013342

t responds to CEOS’s assessment of its limited review of Mr. Epstein’s case; and a point-by- point rebuttal to First Assistant United States Attorney Jeffrey Sloman’s recent letter which we believe contains factual inaccuracies typical of our correspondence from the United States Attorney’s Office in Miami (the “

couraging civil lawsuits against Mr. Epstein under the guise of the terms of the Non Prosecution Agreement. See Tab 35, November 28, 2007 Letter from K. Starr to A. Fisher. Late in the day on November 28, Epstein’s attorneys received from AUSA Villafana a copy of the USAO’s proposed victim-notification let